----- Original Message -----
From: "Joe Subich, W4TV" <k4ik@subich.com>
To: "'Jim Preston'" <jpreston1@cox.net>; <rtty@contesting.com>
Sent: Friday, January 13, 2006 11:07 AM
Subject: Re: [RTTY] ARRL Bandwidth Proposal - FCC Invites Comments
>
> Jim,
>
> ARRL and others promoting regulation by bandwidth have stated
> that the bandwidth limits are maximum and not minimum. Thus
> "conventional" RTTY would receive a significant expansion in
> the available spectrum. RTTY (digital) would no longer be
> excluded from the "phone bands."
>
> In general the most objectionable portions of the ARRL proposal
> are:
>
> 1) the lack of required "listen before transmit" protocols
> for any station which automatically responds to calls
> (also known as "semi-automatic operation").
>
> 2) the lack of a requirement that all digital protocols be
> published and freely available in working form to enable
> monitoring and "self-policing"
>
Number one is covered, in general terms, by 97.101, 97.105, and 97.109(d).
Number two is already explicitly covered in 97.309 (a)(4).
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